CFTC Chairman J. Christopher Giancarlo and CFTC Chief Economist Bruce Tuckman have authored a white paper, “Swaps Regulation Version 2.0: An Assessment of the Current Implementation of Reform and Proposals for Next Steps.” The paper examines five key areas:

• Swaps clearing
• Swaps reporting
• Swap execution
• Swap dealer capital
• End-user exception from clearing and margin rules and related requirements.

The strongest critique is reserved for swaps execution rules, which the authors feel are contrary to Congressional intent and have “stunted” SEF trading.